Privacy

Your privacy and anonymity are very important to us.
To better protect you we provide this notice explaining our information practices and the choices you may make about the way your information is collected and used.

This is the website of Snorer.com Ltd. Our website address is https://snorer.com

Adrian Zacher, Managing Director, is the Data Controller registered with the United Kingdom, Information Commissioner’s Office.

We have appointed an external Data Protection Officer in line with GDPR requirements.

This privacy policy covers:

 

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The way we use information

  • We use email addresses to confirm registration upon the creation of a new newsletter subscription and to supply the services you request and reply to your enquiry.
  • We use return email addresses to answer the email we receive. Such addresses are not used for any other purpose and are not shared with outside parties.
  • On occasion we may send email to addresses of registered users to inform them about changes or new features added to our site.
  • We use non-identifying and aggregate information to better design our website and to inform our decisions on where to offer a service. For example, we may tell a supplier that X number of individuals visited a certain area on our website, or that Y number of men and Z number of women filled out our registration form, but we would not disclose anything that could be used to identify those individuals.
  • Our newsletter is DOUBLE OPT-IN and requires confirmation of a valid email address. You may unsubscribe at any time. Email addresses are not displayed, sold or shared and importantly a name is not required.
  • Finally, we never use, display or share the personally identifiable information provided to us online in ways unrelated to the ones described above.

Our commitment to data security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

Snorer.com is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with all laws concerning the protection of personal information, including the Data Protection Act 1998.

Under the Data Protection Act you have the right to request a copy of the personal information Snorer.com holds about you and to have any inaccuracies corrected. (We charge £10 for information requests and require you to prove your identity with 2 pieces of approved identification). We will use reasonable efforts to supply, correct or delete personal information about you on our files.

Please address requests and questions about this or any other question about this Privacy Policy to our Registered Office:

The Data Protection Officer
Snorer.com Ltd.
2 Baynards Green Farm Cottage, 
Baynards Green
Bicester
Oxfordshire
OX27 7SG
United Kingdom

We have an SSL certificate for our website. You will notice the https in the address bar and/or a padlock symbol.

Suppliers, affiliated sites and linked sites

Snorer.com expects its partners, suppliers and third-party affiliates to respect the privacy and anonymity of our customers. However, third parties, including our partners, affiliates and other content providers accessible through our site, may have their own privacy and data collection policies and practices. For example, during your visit to our site you may link to, or view as part of a frame on a Snorer.com page, certain content that is actually created or hosted by a third party. Snorer.com is not responsible for the actions, ommissions or policies of such third parties. You should check the applicable privacy policies of those third parties when providing information on a feature or page operated by a third party.

Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose Personally Identifiable Information on our site, such as in reviews, message boards, chat areas or in notices you post, that information can be viewed publicly and can be collected and used by third parties without our knowledge and may result in unsolicited messages from other individuals or third parties. Such activities are beyond the control of Snorer.com and this policy.

Changes to this policy

Snorer.com reserves the right to change this policy at any time. Please check this page periodically for changes. Your continued use of our site following the posting of changes to these terms will mean you accept those changes. Information collected prior to the time any change is posted will be used according to the rules and laws that applied at the time the information was collected.

How Snorer.com protects your personal data and anonymity

Snorer.com was set up to provide snorers with a service that they could trust. A central part of achieving such trust is the Snorer.com privacy policy.

It is the rigorous enforcement of this policy that protects your privacy and anonymity, and ensures that your e-mail remains free of the unwanted junk mail that over-runs so many typical e-mail services.

Snorer.com will never sell or pass on your e-mail address without your permission.

Snorer.com will never divulge your name and address as a customer of sleep apnea screening services. Your purchase of such a service cannot infer you have sleep apnea, as the very nature of screening means that, some people are identified as sufferers while others are not.

How data is handled

Snorer.com has, of course, notified under the Data Protection Act, but Snorer.com’s commitment to protecting your privacy goes further than that required by legislation.

If you have any questions about the privacy policy – or any other aspect of the Snorer.com service – please use the contact details below for our Registered Office or email [email protected].

Comments/Reviews/Testimonials

When visitors leave comments, reviews or testimonials on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymised string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you have an account and you log in to this site, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Spam prevention

We collect information about visitors who comment on Sites that use our Akismet anti-spam service. The information we collect depends on how the User sets up Akismet for the Site, but typically includes the commenter’s IP address, user agent, referrer, and Site URL (along with other information directly provided by the commenter such as their name, username, email address, and the comment itself).

Our Contact details

Snorer.com Ltd.
2 Baynards Green Farm Cottage, 
Baynards Green
Bicester
Oxfordshire
OX27 7SG

United Kingdom

Consent

Whenever you give Snorer.com personal data, you are consenting to its collection and use in accordance with this privacy policy, including Snorer.com contacting you by e-mail to let you know about its services and to provide information (not including promotional information) about other newsworthy goods and services in which you may be interested, for example those of organisations such as suppliers of snoring and sleep apnea screening services and snoring/sleep apnea products.

You do, however, have the right at any time to opt out of Snorer.com contacting you in this way, except where this information is included in your purchase.

How does Snorer.com use your personal data?

In addition to the specific uses mentioned elsewhere in this policy, or for which you have given permission, Snorer.com uses your personal data to provide services to you, to carry out newsletter administration, to let you know about other goods and services in which you may be interested, to inform you about changes and improvements to the Snorer.com website and services, and for direct marketing purposes (but you do have the right to opt out of this).

Snorer.com may also use personal data to monitor the use of the site, to record traffic flows and to carry out research about customer demographics, interests and behaviour. Snorer.com does this to better understand the needs of customers.

To whom might Snorer.com disclose your personal data?

Snorer.com has agreements with sleep apnea screening suppliers and medical information companies, regulating how they may use your personal data.

Snorer.com will NOT disclose your personal data unless obliged to do so by law, or where Snorer.com needs to do so in order to run its business (for instance where Snorer.com outsources services for the processing of your anonymised data or for payment).

Payments

We use STRIPE for payment and they will set the following cookies:

Confidentiality

Snorer.com respects the confidentiality of users and employs systems to help keep all data secure. With the increased use of electronic data collection, storage and distribution in healthcare, there is a need to ensure that information transmitted from doctor to doctor is only seen by those whom the sender intends to see it. As more data is generated, so the chance of it going astray increases. Any information exchange may result in a breach of security, but most complaints of a breach of confidence by health professionals are due to casual conversations in public places and not because of failures in electronic security.

Snorer.com protects the confidentiality of information customers send and receive by using a system of password protection and encryption for the website and a data storage solution with in-built security features. Users are also reminded that United Kingdom General Medical Council and British Medical Association guidance states that Doctors should not send any patient identifiable data across the Internet.

Media

If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Security

Snorer.com has security measures in place to help protect against the loss, misuse and alteration of personal data under Snorer.com’s control.

Measuring website activity

Statistics are collected on how and when members use Snorer.com in order to administer the website and to improve services.

Website links

Snorer.com contains hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, and are also likely to use cookies, and we therefore urge you to review them. They will govern the use of personal information you submit, which may also be collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

Cookies

This site, like many others, uses cookies to improve your experience. They cannot be used to identify you.

These pieces of information are used to improve services for you through, for example:

  • Enabling a service to recognise your device so you don’t have to give the same information several times during one task
  • Recognising that you may already have given a username and password so you don’t need to do it for every web page requested
  • Measuring how many people are using services, so they can be made easier to use and there’s enough capacity to ensure they are fast
  • Analysing anonymised data to help us understand how people interact with our services so we can make them better

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.external_link3

You may also use a Google Analytics Opt-out Browser Add-on which is available here: Google Analytics Opt-out Browser Add-on external_link3

Embedded content

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.

Direct marketing

Snorer.com may contact you by e-mail to market its goods and services, but you may at any time request that Snorer.com stops using your personal data for direct marketing purposes. If you wish to do this please contact: [email protected]

Communications data

Snorer.com does NOT retain Communications Data (such as records of the websites you have visited, services you have used, e-mail addresses to which you have sent messages, telephone numbers called, location data, and installation data).

Access to your personal data

Individuals have certain rights of access to their own personal data. If you want to request any information about your personal data, please contact: [email protected]

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Contacting Snorer.com

If you have any questions about this privacy policy, please use our contact form or e-mail Snorer.com at [email protected].

This is the website of Snorer.com Limited, a company registered in England under number 8144806. Our registered office is at:

Snorer.com Ltd.
2 Baynards Green Farm Cottage, 
Baynards Green
Bicester
Oxfordshire
OX27 7SG
United Kingdom.

This second part of our privacy policy explains how we use your personal and health data for Snorer.me Signposting™.

Our patient Signposting service is called Snorer.me Signposting™ (available here: snorer.me)
“Snorer.me Signposting™”, provides UK adult snoring patient signposting to direct snorers to the most appropriate and nearest professional to help them and optimise use of both GP clinical time and finite NHS secondary care sleep diagnostic services.

At Snorer.com our mission is to put an accessible, truly confidential, and affordable health service in everyone’s hands. We are obsessive about high-quality and convenient healthcare and deeply passionate about privacy. We strive to comply with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA), and to be market leaders when it comes to sleep healthcare and privacy.

This policy explains how we use your personal data in relation to Snorer.me Signposting™. We want to help you understand how we work with your data, so that you can make informed choices and be in control of your information. We invite you to spend a few moments understanding this policy. We may update this policy from time to time – however our commitment to your privacy will remain. We invite you to check back to this page for updates.

This part of our privacy policy covers
• Who we are;
• What personal data we hold and how we get it;
• What we use your personal data for;
• Sharing your personal data;
• Retention;
• Data security and transfers; and
• Your rights.

If you have any further questions about how we process your information, please don’t hesitate to get in touch by contacting our Data Protection Officer:
Address: Data Protection Officer, eeZed Ltd., 2 Baynards Green Farm Cottage, Baynards Green, Bicester, Oxfordshire, OX27 7SG, United Kingdom.

Who we are

Snorer.me Signposting™ is delivered by two companies which are both registered in England and Wales:
1. eeZed Limited (company number: 07907333) provides you with the Snorer.me Signposting™ service under licence from Snorer.com Limited (08144806).
2. Snorer.com Ltd. (company number: 08144806) owns the intellectual property in the Snorer.me Signposting™ tool and Snorer.me brand.
The registered office and principal place of business for both companies is: 2 Baynards Green Farm Cottage, Baynards Green, Bicester, Oxfordshire, OX27 7SG, United Kingdom.

Your relationship is with eeZed Limited. When this policy talks about Snorer.me, ‘us’ or ‘we’, it means eeZed Limited. We remove personal identifiers, such as your name, address and contact details from your medical information, and provide some or all of this data to Snorer.com Ltd., which develops and maintains our Clinical Decision Support System (CDSS).

What personal data we hold and how we get it

We use the following categories of personal data:
Personal details
When you register with us, you complete forms and provide us with basic information about yourself, such as your name, date of birth and email address.
Health and medical information
The main type of information we hold about you is health and medical information: information about your health and sleepiness symptoms. This includes details of your interactions with our digital services.

We get this information solely from you. If you use our other services (including our anonymous sleep apnoea test service), we do not and cannot connect the two sets of personal data.

Technical information and analytics

To improve our site and help more snorers, we may automatically collect the following information, when you use the Snorer.me Signposting™ tool (where this is permitted by your device settings):
(a) technical information, including the address used to connect your mobile phone or other device to the Internet, your login information, system and operating system type and version, browser version, time zone setting, operating system and platform, and your location (based on IP address); and
(b) information about your visit, including products and services you viewed or used, site response times, interaction information (such as button presses) and any phone number used to call our customer service number.

We work with partners who provide us with analytics and advertising services (for our services only and not for third party advertising). This includes helping us understand how users interact with our services, providing our advertisements on the internet, and measuring performance of our services and our adverts. Cookies and similar technologies may be used to collect this information, such as your interactions with our services.

Information obtained from third party services

To reassure you of our commitment to your privacy, we have opted NOT to offer login to Snorer.me Signposting™, via shared social media credentials.

What we use your personal data for

The purposes for which we use your personal data and the legal grounds on which we do so are as follows:
• We obtain and use your personal details to establish and deliver our contract with you.
• We obtain and use your medical information because this is necessary for signposting. This includes the information collected through our Snorer.me Signposting™ tool. At your discretion you may choose to share your information with other healthcare professionals as necessary for them to screen you for obstructive sleep apnoea and for the provision of care to you, such as your GP, a sleep-trained dentist, specialist referral services, and diagnosis centres chosen by you for improving your sleep.
• Where you have provided your explicit consent, we will use your medical information (always having removed personal identifiers, such as your name, address and contact details) to improve our healthcare products and services, and our Clinical Decision Support System (CDSS), so that we can deliver better healthcare to you and other Snorer.me Signposting™ users. This medical information (de-identified in the way described above) may include the medical information we hold and your interactions with our CDSS. This does not involve making any decisions about you – it is only about improving our products, services and software so that we can deliver a better experience to you and other Snorer.me Signposting™ users and help achieve our aim of directing you to the most appropriate professional to help with snoring and or sleep apnoea symptoms. Strict confidentiality and data security provisions apply, at all times.
• We may obtain and use data about your precise location where you give your consent (through providing us access to your location), for example, to help direct you to the sleep-trained dentist. We may also derive your approximate location from your IP address.
• We will NOT use your email address and/or phone number to contact you for marketing purposes.
• Based on our legitimate interest in managing and planning our business, we may analyse data about your use of our products and services to, for example, troubleshoot bugs within the CDSS, forecast demand of service and to understand other trends in use, including which features users use the most and find most helpful, and what features users require from us. This does not involve making any decisions about you – it is only about improving our CDSS so that we can deliver better services to you. Strict confidentiality and data security provisions will apply at all times.
• Where necessary, we may need to share personal details for the purposes of fraud prevention and detection.
• We also store your medical information and your interactions with our digital services, for safety, regulatory, and compliance purposes. For example, we may need to review your information and, where necessary, make disclosures in compliance with reasonable requests by regulatory bodies including the General Medical Council, MHRA, and Care Quality Commission, or as otherwise required by law or regulation.
• Where necessary for safety, regulatory and/or compliance purposes, we may audit your other interactions with our services. Strict confidentiality and data security provisions will apply at all times to any such audit and access.

Sharing your personal data with others

We do not share your data. You may opt to share your data with a sleep-trained dentist or a GP (to help you with a snoring and/or sleep problem).
• We may contact you after your use of our service (for anonymised medical research purposes) to understand what actions you took as a result of your use of Snorer.me Signposting™ and what the outcome was.
• We may share with our commercial partners as aggregated anonymised data to show general trends, for example, the number of users of our service.
• We may preserve or disclose information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of our services or the physical safety of any person.

Except as described above, we will never share your personal information with any other party without your consent.

Retention periods

We retain your medical records in accordance with national best practice guidance – in particular, advice provided by the NHS Digital, Records Management Code of Practice for Health and Social Care 2016, and the summary guidance issued by the British Medical Association. The below is a summary of our retention policy, but we may retain records for other periods as required by law or regulation.

Type of record: Screening

Retention period 10 years

Data storage, security and transfers

We do not store your personal health data on your mobile device. We store all your personal health data on secure servers.
Where you have chosen a password that enables you to access certain parts of Snorer.me Signposting™, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

We do not store any credit or debit card information as our service to patients is free.

We anonymise data transmitted to and from Snorer.me Signposting™. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

Your data may be processed or stored via destinations outside the European Economic Area, but always in accordance with data protection law and subject to strict safeguards. For example, we work with third parties to use their software platforms who have servers outside the UK or EEA to send communication emails to our users.

Your rights

You also have specific rights under the GDPR and DPA to:
• Wherever we process data based on your consent, withdraw that consent at any time. You can do this by contacting us [email protected] ;
• Understand and request a copy of information we hold about you.
• Ask us to rectify or erase information we hold about you, subject to limitations relating to our obligation to store medical records for prescribed periods of time;
• Ask us to restrict our processing of your personal data or object to our processing; and
• Ask for your data to be provided on a portable basis.
You may also contact the Information Commissioners Office (the data protection regulator in the UK): Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, telephone: 0303 123 1113 (local rate).

Contact us

For any questions or concerns, you can contact us by sending an email to [email protected] or call on 01235 364121

Content by Adrian Zacher. Page design by Emma Easton | Page last updated 1st April 2019

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